DCT

2:22-cv-10730

Scramoge Technology Ltd v. Volkswagen AG

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:22-cv-10730, E.D. Mich., 04/06/2022
  • Venue Allegations: Plaintiff asserts venue is proper because Volkswagen Group of America, Inc. maintains a regular and established place of business in the district, has previously agreed to venue in a prior case, and because Volkswagen AG is a foreign corporation.
  • Core Dispute: Plaintiff alleges that certain Volkswagen vehicles equipped with wireless chargers infringe three U.S. patents related to the design and operation of wireless power transfer systems.
  • Technical Context: The technology concerns wireless charging systems for mobile devices, a feature increasingly common in the automotive industry to provide convenience to consumers.
  • Key Procedural History: U.S. Patent No. 10,193,392, one of the three asserted patents, was the subject of an inter partes review (IPR) proceeding (IPR2022-00529), initiated shortly before this complaint was filed. In a final written decision, all claims of the ’392 patent (1-8) were found unpatentable and were subsequently cancelled by a certificate issued on December 1, 2023. This cancellation renders the patent unenforceable and may have a dispositive effect on the infringement count related to it.

Case Timeline

Date Event
2008-11-14 ’537 Patent Priority Date
2010-11-02 ’537 Patent Issue Date
2014-01-08 ’392 Patent Priority Date
2014-04-03 ’685 Patent Priority Date
2019-01-29 ’392 Patent Issue Date
2020-01-28 ’685 Patent Issue Date
2022-02-02 IPR Petition Filed against ’392 Patent
2022-04-06 Complaint Filing Date
2023-12-01 IPR Certificate Cancels All Claims of ’392 Patent

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,546,685 - Wireless power transmitting apparatus, issued January 28, 2020

The Invention Explained

  • Problem Addressed: The patent seeks to minimize power loss between a wireless power transmitter and receiver to increase overall efficiency (’685 Patent, col. 1:42-46).
  • The Patented Solution: The invention proposes a specific structure for the soft magnetic substrate that holds the transmitting coils. This structure includes a groove with a surrounding wall and specially shaped "protruding faces" designed to accommodate multiple coils and guide the magnetic flux, thereby reducing leakage and improving the coupling to a receiving device (’685 Patent, Abstract; col. 2:1-20; Fig. 11).
  • Technical Importance: In multi-coil wireless charging systems, managing magnetic flux is critical for maximizing power transfer efficiency and minimizing electromagnetic interference, particularly within the constrained environment of a vehicle dashboard or console (’685 Patent, col. 6:26-34).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 (Compl. ¶11).
  • Essential elements of claim 1 include:
    • A first transmitting coil, a second transmitting coil, and a third transmitting coil positioned on the first and second coils.
    • A substrate to accommodate the coils.
    • The substrate comprises a wall surrounding the coils and two distinct protrusions inside the first and second coils.
    • Crucially, these protrusions each comprise a "stepped portion" to support the third transmitting coil.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,193,392 - Wireless power transfer device and wireless power transfer system, issued January 29, 2019

The Invention Explained

  • Problem Addressed: Wireless power transmitters can generate unwanted harmonic frequencies, or "spurious waves," which cause electromagnetic interference (EMI) with other electronic devices (’392 Patent, col. 1:50-54). Conventional power converters have limited ability to reduce these harmonics (’392 Patent, col. 2:26-30).
  • The Patented Solution: The invention uses a full-bridge inverter controlled by a pulse-width modulation (PWM) signal. The system actively controls the PWM signal's duty ratio to operate at a point where the ratio of the magnitude of a key harmonic to the magnitude of the fundamental frequency is at a minimum, thereby reducing unwanted emissions (’392 Patent, Abstract; col. 3:1-10). The patent discloses that this minimum distortion occurs at specific duty ratios, such as 41% or 32% (’392 Patent, Fig. 17; col. 17:45-48).
  • Technical Importance: This control method provides a way to improve electromagnetic compatibility (EMC), a critical design and regulatory requirement for electronics intended for use in vehicles, where many sensitive systems operate in close proximity (’392 Patent, col. 2:11-16).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 (Compl. ¶17). As noted, all claims of this patent were cancelled via IPR.
  • Essential elements of the now-cancelled claim 1 included:
    • A control part for generating four distinct AC power control signals.
    • A power conversion part with a full-bridge inverter (four switching elements) that generates AC power in response to the control signals.
    • A specific method for generating positive and negative output voltages based on which switches are turned on.
    • A claimed relationship where the output voltage's duty ratio is determined by the "falling time" of the third and fourth AC power control signals.
  • The complaint does not explicitly reserve the right to assert dependent claims.

Multi-Patent Capsule: U.S. Patent No. 7,825,537 - Inductive power transfer system and method, issued November 2, 2010

  • Technology Synopsis: This patent describes a system for maximizing the efficiency of inductive power transfer. The system's control circuit monitors a parameter indicative of power transfer efficiency and automatically adjusts characteristics of the driving current (e.g., frequency) to optimize power delivery, potentially by inducing a self-resonant oscillation in the receiving device's coil (’537 Patent, Abstract; col. 2:11-21).
  • Asserted Claims: The complaint asserts infringement of at least independent claim 1 (Compl. ¶23).
  • Accused Features: The complaint alleges that Volkswagen's in-vehicle wireless chargers, which must adapt to charge different devices, infringe the ’537 patent. The complaint further alleges that Volkswagen induces infringement by providing instructional materials that teach customers to use the charger in the patented manner (Compl. ¶22, ¶24).

III. The Accused Instrumentality

Product Identification

The accused products are certain Volkswagen automobiles that incorporate a wireless charger, identified as the "Volkswagen Antenna Booster (5NA980611)" (Compl. ¶10, ¶16, ¶22). The list of vehicle models includes the Golf R, Golf GTI, ID.4, Atlas, Atlas Cross Sport, Tiguan, Jetta, Arteon, and Taos (Compl. ¶10).

Functionality and Market Context

The accused instrumentality is an in-vehicle wireless charging pad that allows users to charge compatible mobile devices, such as smartphones, without a physical cable connection (Compl. ¶24). The complaint includes a screenshot from a Volkswagen instructional video depicting a user placing a smartphone on the charging pad inside a 2021 Tiguan SEL (Compl. p. 9, ¶24). This feature is marketed as a convenience and technology-forward feature in modern consumer vehicles.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not provided. The following analysis is based on the narrative allegations in the complaint and the patent claims.

  • ’685 Infringement Allegations
    The complaint alleges that the Volkswagen Antenna Booster (5NA980611) has a physical structure that meets the limitations of the ’685 Patent claims (Compl. ¶10-11). The core of this allegation is that the substrate holding the charging coils in the accused device is structurally equivalent to the claimed substrate, which requires a specific arrangement of walls and multiple "stepped" protrusions to support a multi-coil assembly. Verifying this allegation would require physical inspection or discovery.
  • ’392 Infringement Allegations
    The complaint alleges that the accused chargers employ a power conversion and control system that infringes the ’392 Patent (Compl. ¶16-17). The allegation centers on the charger's method of generating and controlling the AC power signal to minimize harmonic distortion. However, the subsequent cancellation of all claims of the ’392 Patent in an IPR proceeding renders this infringement count moot, as there are no longer any valid claims to be infringed.
  • Identified Points of Contention:
    • Structural Mismatch (’685 Patent): A primary point of contention will be factual and related to claim construction. Does the accused "Antenna Booster" actually contain a substrate with the specifically claimed "first protrusion," "second protrusion," and "stepped portion" features? The infringement analysis will depend heavily on the physical construction of the accused device and the court's interpretation of these structural terms.
    • Functional Mismatch (’537 Patent): A key technical question will be whether the accused charger's control system operates according to the claimed method. Does it monitor a parameter "indicative of an efficiency of power transfer" and "automatically" adjust the current's characteristics to "maximize" that efficiency, as required by claim 1 of the ’537 Patent? The defense may argue that the accused system uses a different, more generalized power control scheme that does not map onto the specific feedback loop claimed.

V. Key Claim Terms for Construction

  • For the ’685 Patent:

    • The Term: "stepped portion" (from claim 1)
    • Context and Importance: This term defines a key physical feature of the claimed substrate. The infringement determination for the ’685 Patent hinges on whether any feature in the accused device's substrate can be characterized as a "stepped portion" that supports the third transmitting coil. Practitioners may focus on this term because its interpretation will define the structural scope of the claim.
    • Intrinsic Evidence for a Broader Interpretation: The specification does not provide an explicit definition, which may support an argument that the term should be given its plain and ordinary meaning, covering any ledge, shelf, or change in elevation that provides support (’685 Patent, claim 1).
    • Intrinsic Evidence for a Narrower Interpretation: A party could argue the term is limited by the embodiment shown in the figures, such as the distinct right-angled step depicted in the cross-sectional view of Figure 11 (’685 Patent, Fig. 11).

  • For the ’537 Patent:

    • The Term: "monitoring one parameter indicative of an efficiency of power transfer" (from claim 1)
    • Context and Importance: This term is central to the claimed feedback control method. The case may turn on what qualifies as a "parameter indicative of an efficiency of power transfer."
    • Intrinsic Evidence for a Broader Interpretation: The specification suggests this can be accomplished by monitoring the voltage at an internal node of the base unit's load circuit, implying that indirect measurements are contemplated (’537 Patent, col. 5:18-34). This could support a broader reading that covers various forms of power or voltage monitoring.
    • Intrinsic Evidence for a Narrower Interpretation: The patent's emphasis on inducing self-resonance and maximizing efficiency through a specific feedback mechanism could be used to argue for a narrower construction, requiring that the monitored parameter be directly and tightly coupled to the optimization of transfer efficiency, not just general power regulation (’537 Patent, col. 4:15-24).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Volkswagen both induces and contributes to infringement of the ’537 patent (Compl. ¶24, ¶25). The inducement allegation is supported by claims that Volkswagen's user manuals and online instructional videos actively encourage and instruct customers to use the accused chargers in an infringing manner (Compl. ¶24). The contributory infringement claim is based on the allegation that the wireless chargers are a material part of the invention, are not staple articles of commerce, and have no substantial non-infringing uses (Compl. ¶25).
  • Willful Infringement: The complaint does not allege pre-suit knowledge of the patents. For the ’537 patent, it alleges knowledge "As of at least the filing and service of this complaint" (Compl. ¶24), which can only support a claim for post-filing willfulness. The prayer for relief requests a finding that the case is "exceptional" under 35 U.S.C. § 285, but the complaint does not plead facts sufficient to establish the "egregious" conduct typically required for such a finding based on pre-suit willfulness (Compl. p. 13).

VII. Analyst’s Conclusion: Key Questions for the Case

  1. Impact of IPR: A threshold issue for the court will be the effect of the IPR decision that cancelled all claims of the ’392 patent. This development will almost certainly lead to the dismissal of Count II and may raise questions regarding the overall merits of the litigation as initially filed.

  2. Claim Scope vs. Physical Structure: For the surviving ’685 patent, the case will likely center on a question of structural scope. Can the term "stepped portion," as described in the patent, be construed to read on the physical design of the mass-produced Volkswagen "Antenna Booster"? This will be a classic battle of claim construction and factual evidence from product teardowns.

  3. Intent to Induce: For the ’537 patent, a key question will be one of intent for inducement. Beyond showing that users perform the claimed charging method, the plaintiff must prove that Volkswagen's instructional materials and product design demonstrate a specific intent to encourage infringement of the patented efficiency-maximization method, rather than merely teaching the basic operation of a wireless charger.